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Treatment of Intercompany Transfer Pricing for Tax Purposes: A Survey of Legislative and Administrative Issues

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  • Yuichi Ikeda

Abstract

Tax authorities in several countries have intensified their surveillance of intercompany transfer pricing in recent years. This paper examines the legislative and administrative issues related to the treatment of intercompany transfer pricing for tax purposes. It reviews the existing international guidelines and national rules on methods for determining appropriate transfer prices, as well as the issues related to tax administration practices for the implementation of those rules. Various systems, proposed or introduced to improve the predictability of taxation, are also examined. This paper further reviews the recent discussions on the “commensurate-with-income” standard and the pricing methodologies proposed thereunder. It finally reviews some alternative approaches to international income allocation which are proposed or adopted in lieu of the transfer pricing approach.

Suggested Citation

  • Yuichi Ikeda, 1992. "Treatment of Intercompany Transfer Pricing for Tax Purposes: A Survey of Legislative and Administrative Issues," IMF Working Papers 1992/077, International Monetary Fund.
    • Handle: RePEc:imf:imfwpa:1992/077
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    Cited by:

    1. Ohana, Eduardo Felipe, 1994. "Anotaçoes sobre preço transferência e observaçses sobre o caso brasileiro," Sede de la CEPAL en Santiago (Estudios e Investigaciones) 34033, Naciones Unidas Comisión Económica para América Latina y el Caribe (CEPAL).

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